CRA Update

Matthew Wall CRA Updates

MDW explained the CRA’s latest Transfer Pricing Memo (TPM-17) says government assistance should not be used to lower the fee for related party services using the cost plus a mark-up.

Tax Hyperion Vol 13, Issue 1

Matthew Wall Tax

Carswell’s Tax Hyperion published “Warning: Tax Authorities are Auditing Inter-Company Loans and Other Financial Transactions” by Matthew Wall.

Tax Hyperion Vol 12, Issue 12

Matthew Wall Tax

Carswell’s Tax Hyperion published “Why Transfer Pricing Disputes are on the Rise for Companies of All Sizes” by Matthew Wall.

OECD – Intangibles

Matthew Wall OECD

MDW explained the final revisions to the OECD Guidelines for Chapter VI on Intangibles states the legal owner of intangibles does not have the right to all of the intangible profits.

OECD – Cash Boxes

Matthew Wall OECD

MDW explained taxpayers with a “cash box” in a low or no-tax jurisdiction must review the 2015 OECD Guidelines and might need to revise their corporate structure, transactions between related parties, or both, to mitigate the risk of a dispute.

Bloomberg BNA Interview

Matthew Wall Bloomberg BNA

Bloomberg BNA interviewed Matthew Wall for “Canada to better align with OECD Work on BEPS, Annual Budget Suggests.”

CRA Update TPM 15

Matthew Wall CRA Updates

MDW explained the CRA’s latest Transfer Pricing Memo (TPM-15) on intra-group services reads more like a training manual for auditors, and less like guidance for taxpayers.

CRA Update

Matthew Wall CRA Updates

MDW explained the CRA’s latest Transfer Pricing Memo (TPM-16) on multiple year data continues the Canada-U.S. differences.